The Louisiana Audubon Council and Delta Chapter of the Sierra Club are submitting the following comments regarding the above Draft permits for International Paper Company, Bogalusa Mill.

Air Emissions:

We note that the Table included in the public notice (PN) for estimated air emissions has significant omissions. Based on the TRI data for 2012, submitted to the EPA by Temple Inland (TI), there are several compounds that are not included in the 2014 Public Notice (PN) Table:

• Methanol 800 tons

• Ammonia 60 tons

• Formaldehyde * 18.5 tons

• Hydrochloric acid 38 tons

• Sulfuric acid 17 tons

• Hydrogen sulfide 50 tons (included?)

* carcinogen

Why were these toxic compounds, emitted to the air in 2012, excluded from the proposed draft air permit? TI listed the above air emissions in their submittal to EPA for the year 2012. According to the TI filings with EPA, they emitted 1,081 tons of toxic chemicals into the air of Bogalusa, Louisiana in 2012. This is a 67% increase over their TRI emissions for 2010 (EPA 2012a).

There were 55 tons of combined hydrochloric and sulfuric acids, discharged into the air of Bogalusa in 2012. These chemicals are very corrosive and can cause adverse impacts to the lungs of city's residents. Has LDEQ had any complaints from citizens of health affects of continued emissions over the years? These corrosive acids can also have an adverse affect on the community by accelerating corrosion of metals in homes in the area. Please address this issue in the final permit.

Hydrogen sulfide is a poisonous gas which in large concentrations can cause death and in small concentrations can cause chronic health problems. Residents of Bogalusa have complained about health issues they believe were caused by air pollution from the paper mill.

We do notice that most of the chemicals/particulates in the table have significant increases from the prior permit. Why is LDEQ allowing these increases?

Water discharges into the Pearl River:

According to the latest TRI data (EPA, 2012b) there were 92 tons of toxic pollutants discharged into the Pearl River in 2012. This is a 74% increase over the 2010 TI discharges to the Pearl River. It would appear that the Louisiana Pollutant Discharge Elimination System (LPDES) is a misnomer. Rather than LDEQ reducing discharges of pollutants into the Pearl River, LDEQ is permitting ever-increasing contamination by the mill.

The following toxic chemicals and quantity were discharged into the Pearl River during 2012 (EPA, 2012b) - TRI data submitted by TI)

From 1988 to 2012 there were a total of 60 tons of barium compounds, 416 tons of manganese compounds, 45 tons of zinc compounds, 3 tons of lead, and 3 tons of vanadium discharged by the Bogalusa paper mill into the Pearl River.

Because these toxic heavy metals have been discharged into the Pearl River since 1988 (first TRI record) we request a baseline study of the sediments downstream of each of the three discharge sites. This should be undertaken by the applicant with oversight by LDEQ to assure appropriate protocol. The analysis of the sediments should include all the non-organic toxics including lead, mercury, barium, manganese etc. All of these heavy metals can cause adverse (chronic) impacts to the biota in bottom sediments. Since these heavy metals are hydrophobic, sampling the water column does not provide an indicator of the true concentration in the river bed.

The Pearl River is impaired because of high levels of methyl-mercury in the fish (LDEQ et al. 2003). The predatory fish in the Pearl River have high levels of methyl-mercury making them unfit for consumption. "Women of childbearing age and children less than 7 years of age should consume no more than one meal per month of bass (all species), bigmouth buffalo, or freshwater drum combined from the [Pearl River] . . . (a meal is considered a half pound of fish for adults and children)" (LDEQ et al. 2003).

A Ph.D. dissertation (Daughdrill, 1974) documents that large quantities of mercury were discharged into the Pearl River by the Bogalusa paper mill until mercury slimicides were banned by EPA for use in paper mills in 1972. River sediments below Bogalusa still have elevated levels of mercury.

Pearl River Fishkill, 2011:

The Sierra Club and Audubon Council are concerned that another fish kill will take place as the TI mill increases its toxic discharges into the Pearl River. The discharges in 2011 not only killed recreational fish, mussels and other but killed 26 gulf sturgeon a threatened species protected by the Endangered Species Act. Based on the impacts to the entire Pearl River system and tributaries in 2011, we advise that Temple Inland apply for a Scenic Rivers permit from LDWF.

Conclusion:

Not only are we concerned about the public health issues from air emissions, but our concerns extend to the adverse environmental impacts on the ecosystem of the Pearl River and tributaries. How many additional fish kills will happen during low-flow conditions during the summer months? What has LDEQ done to diminish the paper mills' adverse impact to the human and natural environments?

Of major concern is the fact that the only place which records the toxic discharges into the Pearl River is EPA's Toxic Release Inventory (TRI). EPA requires every facility to report the quantity of each toxic pollutant discharged each year. Evidently LDEQ does not record or keep files on data provided to EPA by the polluter.

TRI is the only source available which quantifies the toxic releases. Evidently, LDEQ does not require those data nor do they provide such data to the public or incorporated these data into its permit system. There are no Louisiana permits which document the maximum allowable quantities of toxic emissions.

We have enclosed two spreadsheets compiled from the TRI data for the Bogalusa paper mill. We hope LDEQ looks at these documents to see the significant increases of toxic released to air and water by the Bogalusa Paper mill. Finally, we oppose the issuance of these deficient permits because they do not regulate nor document the release of toxic pollutants to the air and water.

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